Once the amendment procedure has been implemented, the standard is published. At this stage legal challenges can again be mounted which can further delay the enactment of the proposed standard.

As evidenced by the explanation of the process that OSHA must use in order to place a standard in place it is easy to understand the problem that OSHA has in affecting any expedient change in the workplace. The extended nature of this process has made it difficult for OSHA to react to problems and confusions relative to the enforcement of its rules and standards. If they were forced to start over every time an ambiguity or contradiction appeared, the safety enforcement process would come to a standstill. To avoid this occurring, the agency has developed an informal opinion letter process wherein the agency provides guidance to employers as to how best to comply with a particular standard. This often...
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